How Sustainability Dovetails with ISO 14001: Safety

The first part of this series focused on how ISO 14001 guides us to reduce energy and waste. Now our attention turns to ISO 14001 can help us improve safety. While some may argue that safety is really within the domain of OHSAS 18001 – which follows in almost lock-step to ISO 14001 since it was modeled after that standard – we prefer to use ISO 14001 as our template in this exercise.

Those responsible for crafting the standard also were aware of ISO 14001’s universal adaptability, as evidenced in the introduction to ISO 14001 that states “[The ISO 14001] elements can be aligned or integrated with those of other management systems…such as those for occupational health and safety.” ISO 14001’s definition of “environment” also includes humans as part of the surroundings to be preserved.

Safety is very important in plant settings, where the U.S. Occupational Safety and Health Administration (OSHA) places a strong emphasis on worker safety and health. Any industrial setting is particularly sensitive to health and safety considerations and OSHA’s regulations, 29 CFR 1910, pretty much cover the gamut.

Also critical to follow in plant settings are process safety management (PSM) and preventive maintenance (PM), two potentially important safety harbingers, the absence of which could prove disastrous for workers and even their surrounding neighbors. Glaring examples of what can go wrong by not regularly following a PSM and/or PM program include BP’s accidents at Texas City, Prudhoe Bay, and the Deepwater Horizon oil rig in the Gulf. More recently, the Exxon oil spill in Montana provides another example.

Yet, on their own, regulations, and even detailed and voluminous company procedures or work instructions, don’t make a plant setting more safe or OSHA-compliant. It’s the employees, and more specifically, well-trained and competent employees who understand and follow their job responsibilities to work safely. Enter the elements of ISO 14001 (with a nod to being compliant as well).

Where safety and ISO 14001 overlap is within Element 4.4.1 (resources, roles, responsibility and authority) and Element 4.4.2 (competence, training and awareness), where senior and mid-level management intersect with the frontline workers. So let’s evaluate improved safety as an example of “low hanging fruit” of sustainable opportunities, and apply our ISO 14001 analysis to capture these opportunities and follow them through the objectives and targets exercise.

First, the facility must have a working environmental policy, and incorporate safety goals among its objectives for the plant’s sustainability. Then the two sub-elements of ISO 14001 4.4, implementation and operation, take front and center. It is of paramount importance that the roles, responsibilities and authorities of specific management representatives are in line with the requirements of ISO 14001, that is, their roles are to ensure the plant and its employees operate in a safe and efficient manner while adhering to all applicable environmental, health and safety-related norms and regulations, and in accordance with the requirements of ISO 14001.

Element 4.4.2 indicates that we must be sure that plant personnel working on tasks that have the potential to cause significant (negative) impacts are sufficiently competent and thoroughly understand their responsibilities. The extent of their competency is indicated by their level of their education, internal training and experience, and other subjective factors, which should be documented regularly.

Here, though, rather than perform an aspects/impacts analysis, plant personnel responsible for managing safety would initiate a cross-check of training provided appropriate staff. This would fall under Element 4.4.2, sections a) through d), to ensure the effectiveness of such training, as well as assess the long-term competency of staff trained against observations or nonconformities noted during regular ISO 14001 internal or third-party audits, as well as any regular-interval internal plant safety audits or inspections, or any noted and documented accidents or other employee injuries.
Among the management tools to track the effectiveness of worker safety as a means to minimize accidents, spills, or other considerations that could adversely affect them or the environment (or at the very least, generate excess waste or use natural resources ineffectively), would be linking the PSM and PM schedules. These, in turn, would be linked to worker training spreadsheets as a cross-check, and further evaluated as a final check during any routine internal snvironmantal health and safety (EH&S) and/or environmental management system (EMS) audits. Any noted opportunities for improvements that also could lead to sustainability improvements would be entered into the system as action items for the next round.

Next time, we’ll look at how ISO 14001 helps companies be more clean and profitable.

Gabriele Crognale, PE, is the founder of MCG Associates, an environmental management and sustainability consultancy. His expertise includes ISO 14001 and 26000 facilitation, and related tailored training and the auditing of such systems to identify system shortfalls that could adversely impact an organization. Contact: E-mail: Phone: 617-564-0533.

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